foreignex comptroller handbook

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Other Income Producing Activities

Foreign Exchange

Comptrollers Handbook

Narrative and Procedures - March 1990

Comptroller of the Currency

Administrator of National Banks

I

(Section 813)


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Comptrollers Handbook Foreign Exchange (Section 813)i

Foreign Exchange

(Section 813) Table of Contents

Introduction 1Risks 1Policy 6The Market 12

Examination Procedures 17

Internal Control Questionnaire 25

Verification Procedures 32


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Foreign Exchange (Section 813) Comptrollers Handbook2

including spot and future contracts to sell, in that currency are not equal. Anexcess of assets over liabilities is called a net long position and liabilities inexcess of assets, a net short position. A long position in a currency which isdepreciating will result in an exchange loss relative to book value because, with

each day, that position (asset) is convertible into fewer units of local currency.Similarly, a short position in a currency that is appreciating represents anexchange loss relative to book value because, with each day, satisfaction of thatposition (liability) will cost more units of local currency. (Examples of net openposition schedules appropriate for use in preparing the report of examinationappear below.)

Consolidated Foreign Exchange PositionMay 4, 19XX

(amounts in thousands)

Assets/Purchases LiabiIities/Sales

Monetary Unit, OvernightLimit and Description

ForeignAmount

U.S. $Equivalent of

Local CurrencyBook Value

ForeignAmount

U.S. $Equivalent of

Local CurrencyBook Value

Deutschemark ($3,000M)Ledger Accounts 563,437 239,461 645,013 274,310Spot Contracts 23,502 9,802 15,973 6,709Forward Contracts 790,250 331,905 712,533 296,342Financial Swaps (a) 239,912 100,097 246,131 104,977

1,617,101 681,265 1,619,650 682,338

Net Position (short) 2,549 1,073

Canadian Dollars ($6,000M)

Ledger Accounts 1,016,076 1,017,525 1,029,835 1,030,057Spot Contracts 330,021 328,972 216,225 217,246Forward Contracts 1,202,013 1,203,226 1,301,279 1,302,522

2,548,110 2,549,723 2,547,339 2,549,825

Net Position (long) (b) 771 102

Swiss Franc ($250M)Ledger Accounts (c) 31,768 11,932 36,052 13,571Spot Contracts 1,526 593 2,566 969Forward Contracts 11,174 4,274 6,545 2,521

44,468 16,799 45,163 17,061

Net Position (short) (d) 695 262(a) Includes both forward purchases and sales and corresponding assets and liabilities. Excess liabilities over

assets represents hedging of interest receivable.(b) Split position caused by failure of bank to properly revalue its nostro accounts on a regular basis. Corrected

during the examination.(c) Does not include Swiss Franc 1,000M (US$ 386M) unhedged investment in a Swiss subsidiary and Swiss

Franc 573M (US$ 217M) unhedged investment in branch fixed assets. Unhedged term "long" positionapproved by senior bank management.


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Comptrollers Handbook Foreign Exchange (Section 813)3

(d) Net overnight position in excess of established limit. Formally approved as a special situation by seniormanagement prior to the transaction.

Maturity Gaps. Exchange risk may exist, by virtue of maturity gaps, eventhough the bank has no net open position (assets equaling liabilities). Gaps are

the result of unmatched forward maturities creating days or longer periods ofuneven cash inflows and outflows. For example, a maturity spread of a banksassets, liabilities, and future contracts may reflect a prolonged period overwhich substantial amounts of a particular currency will be received well inadvance of any scheduled offsetting payments (positive gap). The bank mustdecide whether:

To hold the currency in its nostro accounts.

To invest or place it short-term.

To sell it (spot or forward) for delivery at the time the gap begins and to

repurchase it (spot or forward) for delivery at the time the gap ends. To use any combination of those alternatives.

The converse situation, wherein the maturity spread reflects maturing shorter-term liabilities or substantial cash outflows prior to maturities of offsettingassets (negative gap), obviously involves liquidity implications which do notexist in the positive gap. The bank must meet its obligations at maturity.Therefore, it must have the ability to borrow the currency short-term or be in aposition to purchase (spot or forward) for delivery at the time the gap beginsand, perhaps, sell (spot or forward) for delivery at the time the gap ends. Thedecision to close either gap when it is created, or leave it open until a laterdate, is determined by analyzing the money market interest rates, as well as thedifference (the swap rate) between any applicable spot and forward, or twoforward, exchange rates. The loss exposure, or profit potential, for the bank ismeasured by the anticipated, or actual, movement in the swap rate between thetime the gap is created and the time it is closed. The interrelationship betweeninterest rates and the swap rate as well as the conversion of the swap rate to anannual percentage rate and vice versa, are discussed in subsequent paragraphs.(Examples of maturity distribution schedules appropriate for use in preparingthe report of examination appear below. Note that they balance to the openposition schedules above.)


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division management.

Although controlled and monitored by senior management, day-to-daysupervision of net positions and maturity gaps is usually the responsibility ofthe foreign exchange and money market traders and, perhaps, a line supervisor.

However, regardless of the care with which those functions are managed,factors beyond the direct control of bank officers affect liquidity and exposureto interest and exchange rate movement. Proper evaluation of such factorsrequires close coordination and effective communication among the trading,lending, correspondent relations, and economic research functions within thebank. Some such exposure factors may be identified as follows:

Customer Creditworthiness and Delivery Capabilities. In entering into anymoney market or foreign exchange transaction, the bank must be confident thatthe counterparty possesses the financial soundness and liquidity required to

meet his or her obligations at maturity.

Money market assets expose the bank to credit risk on the entire amount oftheir face value. The liquidity considerations arising from the unanticipatednon-repayment of those assets, particularly when proceeds are intended to meetmaturing liabilities presumably in the same currency, should be obvious. Thebank must satisfy its liability and again fund the asset, perhaps for anundetermined period and at a relatively unfavorable rate.

Foreign exchange transactions may involve the same liquidity and rate risks asmoney market transactions. However, the inherent credit risks are measureddifferently. Foreign exchange transactions are normally considered to be voidof, or contain less than face value, credit risk except on the day(s) on whichthey are settled. For example, every foreign exchange transaction involves theexchange of one currency for another. If a counterparty is unable to deliver atmaturity the currency that it has contracted to sell, the bank must either disposeof the currency it acquired for delivery under the contract or purchase thecurrency that it had expected to receive and had, in turn, contracted to deliverto a third party. If the bank had known in advance that the counterparty woulddefault, its exchange risk exposure would have been determined by thedifference between the contracted rates and the rates (spot or forward) at which

funds could be obtained between the time it received prior warning and thematurity of the contract. Some bankers would attribute the rate difference tocredit risk, although others would maintain that no credit risk existed prior tosettlement date because there would be no need for funds to be paid or


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exchanged. However, of importance is the fact that the bank in that instancewould not lose the full amount of the contract. If the bank had not receivedprior warning, the liquidity considerations could obviously be more severe.Also, the banks exposure (depending on whether it had or had not transferred

its payment prior to knowledge of default) would range from an exchange profit(less nostro overdraft charges relating to the sale contract to the third party) to acredit loss equal to the face amount of the defaulted contract. In that regard,credit (delivery) risk is considered to be more severe when the home country ofone or both of the currencies being traded lies to the east of the bank. Forexample (assume the bank is selling a European currency for U.S. dollars), mostEuropean clearing mechanisms would not accept items for processing on thesame day if they were received after 12 noon. Thus, to meet European clearingrequirements on settlement (maturity) date, a United States bank must advise itsEuropean correspondent by cable on the previous business day to charge its

account and credit the account of the counterparty. This is done without theUnited States banks knowledge of whether the counterparty will advise (or beopen for business to advise) its U.S. correspondent to make a similar transfer,e.g., to charge its account and credit that of the United States bank. If, in fact,the foreign bank does not advise its U.S. correspondent to make the transfer,the United States bank could lose the entire face amount of the contract. Insummary, the credit risk is generally limited to the difference between thecontracted rate and the prevailing spot rate except on maturity date when thepossibility of delivery against nonreceipt of counterpart funds could result in aloss of the full face value of the contract.

Economic and Political Considerations. Political changes and/or adverseeconomic trends within a country are likely to be accompanied by shifts inpolicies which often affect such factors as interest rates, investment levels,capital flows, overall payments balances, and foreign exchange reserves. Suchpolicies, whether based on economic necessity or changing attitudes, mightaffect the availability of exchange to counterparties or the banks brancheswithin the country or even the convertibility of that countrys currency in othermarkets. In either case, the exchange rates for that currency will be subject toadditional demand and supply considerations while sources of cover or

liquidity in that currency may vanish.

Policy

The relative importance of each of those risk determinants varies with each


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currency traded and with the country of each counterparty. Senior bankmanagement must fully understand the risks involved in foreign exchange andmoney market operations and must establish, in writing, its goals and policiesregarding those risks. Management must be able to defend logically the basisupon which such policies are formed. It is imperative that responsible officers,

traders, clerks, and auditors understand, without exception, the intent as wellas the detail set forth in those directives.

At a minimum, policies should define dealing limits and reporting requirementsas well as accounting, adequate audit and control systems to provide propersurveillance over those limits and exceptions thereto.

Limits must be established for overnight net positions in each currency.Depending on the size of the limits and the manner in which they arecalculated, a smaller aggregate position limit for all currencies may be

desirable. An aggregate limit should not permit the netting of short against longpositions but should require that they be added to determine conformance tothat limit. Many U.S. banks presently are considering daylight (intraday)position limits which are practical only if efficient computerization and inputsystems are in effect to incorporate each trade into the appropriate currencyposition at nearly the precise moment it is transacted. A common argumentagainst intraday limits is that traders will only take those daylight positions theycan cover by the end of the day. The solution to that argument might well lie inthe frequency with which overnight position limits are exceeded and the reasonfor each excess position.

Gap (net inflow and outflow) limits must be instituted to control the risk ofadverse rate movement and liquidity pressures for each currency per each daily,weekly, or bi-weekly future time frame designated in the banks maturityreports. Such limits might range from stated absolute amounts per time frameto weighted limits which emphasize increasing rate movement exposureapplicable to the relative distance into the future in which the gap appears.

Aggregate trading and placement limits must be established for each customer,based primarily on the amount of business considered to be appropriate to its

creditworthiness and, secondly, on the volume of its foreign currency needs. Inaddition, absolute sub-limits should be placed upon the amount of thatcustomers business that may be settled on one day. Should the customer beunable to meet obligations on one day, the trader will:


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In most instances, an additional report reflecting those items at final maturity isdesirable in analyzing the banks medium and longer-term dependence onmoney market funding sources.

Exception reports must be generated immediately upon the creation of excesses,

to position limits, gap limits, and customer trading and settlement limits.Excesses over any established limits should conform to overall policy guidelinesand should receive prior approval by the responsible supervisory officers. Ifprior approval is not possible, evidence of subsequent supervisor concurrenceor disagreement as well as any corrective action should be available for auditreview and management records.

Revaluation and Accounting Systems. Such systems should accuratelydetermine actual as well as estimated future profits and losses and present themin such a manner as to facilitate proper income analysis by management, bank

supervisory personnel, and the public. One system widely used by banks isillustrated below. This system is capable of presenting separately, each of thefollowing:

Actual realized profit or loss as determined by applying current spot rates tobalance sheet accounts as well as contracts of very near maturities.Adjustments to the local currency book values would either be allocated andposted to each of the applicable local currency ledger accounts or, for shortinterim periods, be charged to a separate foreign exchange adjustmentaccount with an offset to P&L.

Unrealized (estimated future) profit or loss on future transactions asdetermined by applying the appropriate forward rates to the net positionsreflected for each future period appearing in the banks gap or maturityreports. An estimated profit (loss) on foreign exchangefutures accountwould be charged for the amount of the adjustment with an offset to P&L.Provided that the amount of that adjustment is the difference between theexisting forward rates and the actual contract rates, each months entriesmerely involve reversing the adjustment from the prior revaluation andsubmitting the new figures.

The previous discussion may be more clearly understood when read inconjunction with the typical bank revaluation worksheet below. The illustrationreflects a revaluation of the Deutschemark position above.


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As discussed in subsequent paragraphs entitled Financial SwapsandArbitrage, simultaneously contracted spot purchase and future saletransactions performed to acquire foreign currency funds for temporary loanor investment purposes should be segregated from regular trading activities

when determining revaluation profits or losses. Those swap profits(discounts) or costs (premiums), as determined by the difference in localcurrency value between the two contracted rates, are fixed. They are locked-in at the time the forward side of the swap is completed. They should beamortized or accreted over the life of the swap and must be properlyallocated to reflect the true yield on the particular investment for which theswap was entered and the real income from loans and securities.

Revaluation WorksheetMay 4, 19XX

(amounts in thousands)

Deutschemark Assets LiabilitiesNet

Position RateMarketValue

BookValue

Profitor Loss

Ledger Accounts 563,437 645,013 -81,576 .39155 -31,941 -34,849 + 2,908 (a)Spot Contracts 23,502 15,973 + 7,529 .39155 + 2,948 + 3,093 -145 (a)Forward ContractsDec. 21 to Jan. 20 0 56,926 -56,926 .39230 -22,332 -21,986 -346 (b)Jan. 21 to Feb. 20 100,415 111,420 -11,005 .39335 -4,328 -4,328 0 (b)Feb. 21 to Mar. 20 56,246 49,457 + 6,789 .38795 + 2,635 + 2,578 + 57 (b)Mar. 21 to Apr. 20 0 0 0 0 0 0 (b)Apr. 21 to May 20 203,717 200,315 + 3,402 .38810 + 1,320 -177 + 1,497 (b)May 21 to Jun. 20 0 0 0 0 0 0 (b)Jun. 21 to Jul. 20 98,426 0 + 98,426 .38825 + 37,648 + 37,117 + 531 (b)

Jul. 21 to Aug. 20 301,226 295,556 + 5,670 .38830 + 2,202 + 2,475 -273 (b)Aug. 21 to Sep. 20 37,427 39,256 -1,829 .39350 -718 + 2,547 -3,265 (b)Sep. 21 to Oct. 20 0 0 0 0 0 0 (b)Oct. 21 to Nov. 20 222,705 185,716 + 36,989 .38875 + 14,379 + 16,413 -2,034 (b)Nov. 21 to Dec. 20 0 0 0 0 0 0 (b)Dec. 21 and over 10,000 20,018 -10,018 .39420 -3,949 -3,956 + 7 (b)Total 1,617,101 1,619,650 -2,549 -2,136 -1,073 -1,063 (b)(a) Allocated to appropriate balance sheet accounts with offset to P&L.(b) Allocated as credit to unrealized loss account and debit to P&L.

The Financial Accounting Standards Boards (FASB) Statement of FinancialAccounting Standards No. 8 prescribes a different approach to portfolio

valuation than that previously described. The principles and procedures setforth in that statement are outlined as follows:

Balance sheet accounts denominated in foreign currencies should be


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the FASB method.

Departmental Organization and Control. It is imperative that there be adistinct separation of duties and responsibilities between the trading and the

accounting and confirmation functions within the department. The manyopportunities for greater bank profit or personal financial gain, whether byspeculating beyond loosely controlled limits, concealing contracts because ofpoor confirmation procedures, or by simple fraud, may be too tempting even tothe most trusted employees. Periodic audits and examinations are no substitutefor sound continuing safeguards, and the numerous guidelines in the InternalControl Questionnaire in this section cannot be overemphasized.

Supervision of Branches and Subsidiaries. Whether a bank maintains centralcontrol over all foreign exchange and money market activities at the head office

or elects to decentralize that control, the policies, systems, internal controls,and reporting procedures should not differ among separate offices within thebank.

In either case, the bank should be apprised of its worldwide positions by dailysummary reports. Detailed net position and maturity gap reports should bereceived periodically in order to prepare consolidations, as required, and tomonitor individual unit trading volume and funding methods. Informationprovided in the Treasury Department monthly foreign currency reports isadequate for the preparation of reports of examination and can be adapted

easily to reporting for currencies other than those specified in the reportinginstructions.

Federal Financial Institutions Examination Council Uniform Guideline. TheOCC adopted the Uniform Guideline on Internal Control for Foreign Exchangein Commercial Banks on June 11, 1980. This guideline establishes minimumstandards for documentation, accounting, and auditing for foreign exchangeoperations of banks supervised by the OCC, the Federal Deposit InsuranceCorporation, and the Federal Reserve System. The minimum standards adoptedeither have been incorporated into the Foreign Exchange Internal Control

Questionnaire or are already included in the Handbook sections on InternalControl, Internal and External Audits, and Working Papers.

The Market


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Banks may fund their foreign currency activities through either money markettransactions or foreign exchange transactions, or both. Money marketinstruments exist in a variety of forms and under a number of different names.However, each of them can be categorized as a type of deposit, loan, orborrowing and are all specifically covered in other sections of this handbook.

Therefore, only market considerations most applicable to foreign exchange arediscussed here.

Spot Exchange. Although the spot market typically refers to the purchase or saleof foreign exchange for delivery in 2 business days, many U.S. banks considertransactions maturing in as many as 10 business days as spot exchange. Thelatter definition is used generally to facilitate revaluation accounting policiesand to initiate final confirmation and settlement verification procedures onfuture contracts nearing maturity.

The spot rate for any particular currency might be determined strictly by the bidand offered rates at which the central bank of that country will officially trade.It might be pegged to another currency or group of currencies or allowed tofloat freely in accordance with supply and demand. However, the rate maychange at any time based on many overriding economic, political, or marketfactors.

Forward Exchange. Future exchange contracts are typically made for delivery in1, 2, 3, and 6 months, i.e., actual deliveries are made in exactly the statednumber of months from the normal spot date. In most major currencies,

however, contracts can be made for odd dates or in the exact number of daysdesired by the counterparty. Odd date rates can generally be determined byinterpolation between spot and forward rates or between two forward rates.

Forward exchange rates usually are quoted in terms of their premium ordiscount over spot. Though they move with fluctuations in the spot rate, theamount of the premium or discount (the swap rate) is determined by the netaccessible interest rate differential existing between the two countries, e.g., thedifference in interest rate levels further adjusted for reserve requirements andother cost factors. The currency of the country in which interest rates are higher

will sell at a forward discount relative to the currency of the lower interest rateand vice versa. For example, if the net accessible interest rate in a country werehigher by 3 percent per annum than that in the United States, and the spot ratefor that currency was U.S. $2.4000, then the forward discount normally wouldbe $.0720 per year (2.4000 x .03), or $.0060 per month. Should the forward


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discount move from the 60 points per month, there will immediately be anopportuni ty for arbitrage through a financial swap.

Financial Swaps. A financial swap is the combination of a spot purchase or sale

against a forward sale or purchase of one currency in exchange for another. It ismerely trading one currency (lending) for another currency (borrowing) for thatperiod of time between which the spot exchange is made and the forwardcontract matures. The swap is the simple identification of one transactioncontracted at the spot rate with another contracted at the forward rate toestablish the exchange cost or profit related to the temporary movement offunds into another currency and back again. That exchange (swap) profit or costmust then be applied to the rate of interest earned on the loan or investment forwhich the exchange was used. For example, the true yield of an investment for90 days in United Kingdom Treasury bills cannot be determined without having

considered the cost or profit resulting from the swap needed to make poundssterling available for that investment. By the same token, the true trading profitsor losses generated by the trader cannot be determined if financial swap profitsand expenses are charged to the exchange function rather than being allocatedto the department whose loans or investments the swap actually funded.

Arbitrage. As it pertains to money markets and foreign exchange, arbitrage maytake several forms. The creation of an open position in a currency inanticipation of a favorable future movement in the exchange rate, in addition tobeing speculative, is sometimes referred to as arbitrage in time. Buying a

currency in one market and simultaneously selling it for a profit in anothermarket is called arbitrage in space. Slightly more complicated is the practice ofinterest arbitrage that involves the movement of fund from one currency toanother so they may be invested at a higher yield. The real yield advantage insuch a situation is not determined merely by the difference in interest ratesbetween the two investment choices, but rather, by subtracting the cost oftransferring funds into the desired currency and back again (the swap cost) fromthe interest differential. For example, in the situation described under ForwardExchange, there is no arbitrage incentive involved in swapping from dollarsinto the other currency at a 60 point per month discount (swap cost) which

exactly offsets the 3 percent gain in interest. However, should the swap ratemove to 40 points per month (or 480 points per year), the investment mightbecome attractive. This can easily be tested by converting the swap rate to anannual percentage rate


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Discount or Premium x 360 x 100Spot rate x No. of days of future

contract

= % P.A.

.0040 x 360 x 100

2.4000 x 30 = 2% P.A.

which results in a true yield incentive of 1 percent, 3 percent less the swap costof 2 percent.

As discussed earlier, unless the banks accounting system can identify swapcosts or profits and allocate them to the investments for which they wereentered, both the earnings on those investments and the earnings upon whichthe traders performance are measured will be misstated.

Options. Option contracts permit a bank to contract to buy from or sell to acustomer when that customer can only generally predict the dates betweenwhich he or she must trade. The option contract specifies both dates, and therate cited is that which in the judgement of the trader at the time of making thecontract contains the least exposure for the bank. That type of contract iscommonly requested by commercial customers wishing to cover drafts drawnunder letters of credit denominated in foreign currency. Such contracts arealways risky since there is no way for the bank to acquire a precisely matchingcover.

Compensated Contracts. There are occasions when both parties are agreeableto altering the terms of an existing contract. Such alterations should beapproved by an impartial bank officer. Operations personnel must be advised ofeach compromise to avoid settlement in accordance with the originalinstructions and terms.

Foreign exchange and money markets do not merely exist but must be createdby parties who are willing to engage in commercial and financial transactionsproposed to them by others. If a bank wishes to solicit such business, it mustbe prepared to quote bid and offered rates of exchange or interest for a given

time period. The party requesting the rates has the option to buy or sell, depositor borrow, at the stated rates or decline to deal. If the quoting bank prefers onlyto service its commercial customers needs and otherwise remain relativelyinactive, it will have to acquire cover for those transactions at another partysbid and offered rates compared to an active bank that has the advantage of


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dealing more frequently at its own rates. In addition, active market participationmay enhance a banks ability to borrow. It is important that those factors beconsidered in evaluating a banks trading volume and liquidity.


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Foreign Exchange

(Section 813) Examination Procedures

1. Complete or update the Foreign Exchange section of the Internal ControlQuestionnaire.

2. Based upon the evaluation or internal controls and the work performedby internal and external auditors (see separate program), ascertain thescope of examination.

3. Test for compliance with policies, practices, procedures, and internalcontrols in conjunction with the remaining examination procedures.Also, obtain a listing of any deficiencies noted in the latest review doneby internal/external auditors from the examiner assigned Internal and

External Audits, and determine if appropriate corrections have beenmade.

4. Perform appropriate verification procedures.

5. Obtain a trial balance, including local currency book values, of customerspot and future contract l iabili ties by customer and by maturity, and:

a. Agree or reconcile balances to appropriate subsidiary controls and tothe general ledger.

b. Review reconciling i tems for reasonableness.

6. Using the appropriate sampling technique, select customers forexamination. If verification procedures have been performed, use thesame sample. (Refer to step 20 before performing steps 7 through 19.)

7. Prepare credit line sheets to include details below:

a. Customers aggregate foreign exchange liability in local currency

equivalents.

b. Customers assigned trading volume limit.

c. Transcribe book value equivalents of individual contracts (from the


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trial balance obtained at step 5) in maturity order, indicating theforeign currency amount of each. If contracts are voluminous,summarize transcription to include:

The average book value per contract. The combined book value amount, purchases plus sales, and date

of the largest single days settlement.

The longest outstanding maturity.

The total of all future contracts in each foreign currency.

d. Customers assigned daily settlement limit.

e. Frequency of recent overdrafts in current account and, if possible,whatever reasonable identification can be made to late delivery of

prior foreign exchange contract maturities.

f. Past compliance with trading volume and settlement limits asdetermined from review of liability ledger record.

8. Identify those contracts with counterparties who are affiliates of orotherwise related to the bank, its directors, officers, employees, or majorshareholders, and:

a. Compare the contracted rates with available rates for the same

transaction date or with other contracts entered as of the sametransaction date for the same tenor.

b. Investigate any instances involving off-market rates.

9. Obtain from the examiner assigned International Loan PortfolioManagement the schedules on the following if they are applicable to theforeign exchange area:

a. Delinquencies.

b. Shared national credits.

c. Interagency Country Exposure Review Committee credits.


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d. Previously cri ticized loans (internally or by examiners).

e. Information on directors, executive officers, principal shareholders,and their interests.

f. Any useful information resulting from the review of the minutes ofthe foreign exchange and money market committee or any similarcommittee.

g. Reports furnished to the foreign exchange and money managementcommittee or any similar committee.

h. Reports furnished to the board of directors.

i. A list of affiliated companies.

10. Transcribe or compare information from the above schedules to creditline sheets, where appropriate.

11. Prepare credit line sheets for any foreign exchange customer not in thesample which, based on information derived from the above, requires in-depth review.

12. Obtain l iability and other information on common borrowers fromexaminers assigned to cash items, overdrafts, and loan areas, and,

together, decide who will review the customer relationships. Pass orretain completed credit line sheets.

13. Analyze each customer relationship considering the guidelines set forthin the international sections, as they pertain to:

a. Commercial loans for private and commercial counterparties.

b. Due from foreign bankstime for banking and financialcounterparties.

(Generally, a customers obligation to the bank under foreign exchangecontracts would not be classified. However, if a customers financialcondition is so severe, i.e., doubtful or loss, that its ability to meet itsforeign exchange commitments is questionable, the combined book value


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of contracts, purchases plus sales, representing the largest single dayssettlement should be appropriately criticized or classified.)

14. Review the most readily available record and/or source of spot exchange

rate movement vis-a-vis the local currency to determine whichcurrencies, if any, have experienced a substantial degree to appreciationor depreciation over the recent past. (Give particular attention, in step13, to the creditworthiness of those counterparties who have contractedeither to deliver appreciating currencies to, or purchase depreciatingcurrencies from, the bank. In the event of non-performance by acounterparty that has agreed to (a) deliver an appreciating currency, thebanks cost to cover any offsetting sales contracts might be substantial,or (b) purchase a depreciating currency, the bank might be forced to sellthe currency it had acquired for delivery at a substantial loss. As one

source for identifying such currencies, each monthly Federal ReserveBulletin provides a history of annual and monthly averages of certifiednoon buying rates in New York for cable transfers.)

15. Obtain or prepare the following data (separately for each foreigncurrency involved, and to include book value equivalents), as of theexamination date, to be used in performing subsequent examinationsteps:

a. A list of subsidiary control ledger totals for all balance sheet and

memoranda general ledger accounts by account number and/or title.

b. A trial balance of all balance sheet asset and liability items bymaturity.

c. A trial balance of all spot and future exchange contracts by maturity.

d. Copies of the traders daily position sheets and/or reports.

e. Copies of the accounting departments daily position sheets and/or

reports and reconcilements to the traders positions.

f. If not included in copies obtained under d and e, a detailed listing ofall holdover and after-hour transactions.


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g. If not available as of examination date, copies of the accountingdepartments last maturity gap reports. (After analysis has beenperformed, pass maturity gap reports, to include appropriate localcurrency equivalents, to the Funds Management examiner.)

h. If not prepared as of examination date, copies of the last revaluationworksheets.

i. All limit exception reports.

16. Prepare examination report net position and maturity schedules, and:

(Commitments to take or place foreign currency deposits must beincluded in the maturity schedules in order that all anticipated cashinflows and outflows are properly reflected. However, those items

should not be included in the net position schedules other than infootnote form.)

a. Compare results to bank prepared net position and maturity gapreports, if available for the same date.

Footnote any material differences.

Explain any deficiencies.

b. Compare results to established limits, and review exception approvals

thereto.

17. Check the most recent revaluation working papers and resultantaccounting entries to determine that:

a. Foreign currency amounts and book values were properly reconciledto subsidiary ledger controls.

b. Rates used are representative of market rates as of revaluation date,and

If obtained from the traders, that they have been verified withindependent sources. (Daily, 10:00 AM, mid-point, spot andfuture, New York interbank market rates for commonly tradedcurrencies are available as needed at each regional office or the


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International Banking Activity Examinations, Washington, D.C.)

c. Arithmetic is correct.

d. Profit and loss results are separately recorded and reported tomanagement for:

Realized profit or loss, i.e., that which is determined through theapplication of spot rates.

Unrealized (estimated future) profit and loss, i.e., that which isdetermined through the application of forward rates.

e. Financial swap related assets, liabilities, and future contracts areexcluded from the normal revaluation process so that the results

identified in d. reflect more accurately the traders outright dealingperformance.

f. Financial swap related costs and profits are:

Amortized over the life of the applicable swap.

Appropriately accounted for as interest income and expense onloans, securities, etc.

18. Review working papers for selected revaluations performed since last

examination, and test check as in step 17 above, and, if satisfied thatthey are accurate:

a. Analyze combined realized earnings to determine that profits arecommensurate with risks taken.

b. Analyze monthly unrealized revaluation results (forecasts) todetermine that:

The resulting amount for the last revaluation, if a loss, is not large.

An increasing loss trend over previous revaluations does not exist.(Although month-to-month variations are not uncommon, anincreasing unrealized loss trend could indicate that a trader iscaught in a loss position and is pursuing a notion that a negativetrend in the exchange rate for that currency will reverse and, if


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combined with an ever multiplying increase in his or her volume,might eventually repay his or her accumulated losses.)

19. Review the confirmation discrepancy log, and observe the confirmationprocess to determine:

a. That incoming confirmations are delivered directly to theconfirmation clerk and that:

Discrepancies are recorded.

Discrepancies are reported to an appropriate officer and areresolved promptly.

b. That outgoing confirmations are processed in compliance withpolicies governing:

Initial procedures.

Follow-up procedures.

The level of involvement by internal auditors in follow-upprocedures.

c. If the confirmation discrepancy log discloses counterparties which:

Are often or consistently slow in confirming.

Often or consistently make errors in confirmation preparation.

20. Determine compliance with laws, regulations, and rulings pertaining toforeign exchange activities by performing the following for:

a. 12 CFR 20.5 Monthly Consolidated Foreign Currency Report ofBanks and Federal Branches Form FFIEC 035:

Review for accuracy the most recently prepared monthly report.

Select random bank prepared net position reports, and determinewhether they are being filed as required and are accurate.

(Be alert to instances in which net positions are generally large butreduced as of the month-end reporting dates.)

21. Discuss with appropriate officer(s), and prepare appropriate reportsummaries of:


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a. Net position schedules.

b. Maturity gap schedules.

c. Frequent or sizeable excesses over any established limits.

d. Any limits deemed excessive relative to:

Managements policy goals regarding the nature and volume ofbusiness intended.

The banks capital structure.

The creditworthiness of trading counterparties.

Individual currencies for which limited spot and future markets

exist. Experience of traders.

The banks foreign exchange earnings record.

e. The absence of any limits deemed appropriate in present andforeseeable circumstances.

f. Customers whose obligations are otherwise previously classified orintended to be criticized.

g. Foreign exchange contracts which, for any other reason, arequestionable in quality or ultimate settlement.

h. Violations of laws, regulations, or rulings.

i. Deficiencies in internal controls.

j. Other matters regarding efficiency and general condition of theforeign exchange department.

22. Prepare a memorandum, and update the work program with anyinformation that wil l facil itate future examinations.


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Foreign Exchange

(Section 813) Internal Control Questionnaire

Review the banks internal controls, policies, practices, and proceduresregarding foreign exchange trading. The banks systems should be documentedin a complete and concise manner and include, where appropriate, narrativedescriptions, flowcharts, copies of forms used, and other pertinent information.Items marked with asterisks require substantiation by observation or testing.

Policies

1. Has the board of directors, consistent with i ts responsibilities, adoptedwritten policies governing:

a. Trading limits, including:

Overall trading volume?

Overnight net position limits per currency?

Intra-day net position limit per currency?

Aggregate net position limit for all currencies combined?

Maturity gap limits per currency?

Individual customer aggregate trading limits, including spottransactions?

Written approval of excesses to above limits?

b. Segregation of duties among traders, bookkeepers, and confirmationpersonnel?

c. Accounting and revaluation procedures?

d. Management reporting requirements?

2. Do policies attempt to minimize:

a. Undue pressure on traders to meet specific budgeted earnings goals?

b. Undue pressure on traders, by account officers, to provide preferredrates to certain customers?


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3. Are traders prohibited from dealing with customers for whom tradinglines have not been established?*

4. Are all personnel, except perhaps the head trader, prohibited fromeffecting transactions via off-premises communication facilities?

5. Is approval by a non-trading officer required for all compensatedtransactions?

6. Do credit approval procedures exist for settlement (delivery) risk eitherin the form of settlement limits or other specific management controls?

7. Does a policy procedure exist to insure that, in the event of an uncertain

or emergency situation, the banks delivery will not be made prior toreceipt of counterpart funds?

8. Do the above policies apply to all branch offices as well as majority-owned or controlled subsidiaries of the bank?

9. Does the bank have written policies covering:

a. Foreign exchange transactions with its own employees?

b. Foreign exchange transactions with members of its board of directors?

c. Its traders personal foreign exchange activities?

d. Its employees personal business relationships with foreign exchangeand money brokers with whom the bank trades?

10. Are the above policies understood and uniformly interpreted by alltraders as well as accounting and auditing personnel?*

Trading Function

11. Is a traders position sheet maintained for each currency traded?

12. Is a traders position report received by management at the end of each


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trading day?*

13. Does the traders position report reflect the same days holdover andafter-hours transactions?*

14. Are traders dealing tickets pre-numbered?

a. If so, are records and controls adequate to ascertain their propersequential and authorized use?

b. Regardless of whether or not pre-numbered,*

Are dealing tickets time date stamped, as completed, or

Are dealing tickets otherwise identified with the number of theresultant contract to provide a proper audit trail?

Accounting and Reporting

15. Is there a definite segregation of duties, responsibility, and authoritybetween the trading room and the accounting and reporting functionswithin the division and/or branch?*

16. Are contract forms pre-numbered (if so, are records and controlsadequate to insure their proper sequential and authorized use)?

17. Are contracts signed by personnel other than the traders?

18. Are after-hours or holdover contracts posted as of the dates contracted?*

19. Do accounting personnel prepare a daily position report, for eachapplicable currency, from the banks general ledger, and:*

a. Do reports include all accounts denominated in foreign currency?

b. Are those reports reconciled daily to the traders position report?

c. Are identified or unreconciled differences reported immediately tomanagement and to the head trader?

d. Are all counterparty non-deliveries on expected settlements reported


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immediately to management and to the head trader?

20. Are maturity gap reports prepared for liquidity and foreign exchangemanagers at least bi-weekly to include:*

a. Loans and deposits reflected in the appropriate forward maturityperiods along with foreign exchange contracts?

b. Loans, deposits, and foreign exchange contracts (specify whetherreflected in the maturity periods in which they fall due or in whichthey are scheduled for rollover ____________)?

c. Commitments to accept or place deposits reflected in the appropriatematurity periods by both value and maturity dates?

d. All those items (specify whether as of the day on which they matureor bi-weekly or monthly maturity periods ____________)?

e. All those items as of the day on which they mature, if necessary, i.e.,in the event of a severe liquidity situation?

21. Does the accounting system render excesses of all limits identified atstep 1 immediately to appropriate management, and is officer approvalrequired?*

22. Are local currency equivalent subsidiary records for foreign exchangecontracts balanced daily to the appropriate general ledger account(s)?*

23. Are foreign exchange record copy and customer liability ledger trialbalances prepared and reconciled monthly to subsidiary control accountsby employees who do not process or record foreign exchangetransactions?*

24. Do the accounting and filing systems provide for easy identification of

financial swap related assets, liabilities, and future contracts bystamping contracts or maintaining a control register?

Confirmations


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25. Is there a designated confirmation clerk wi thin the accounting sectionof the division or branch?

a. Incoming Confirmations:*

Are incoming confirmations delivered directly to the confirmationclerk and not to trading personnel?

Are signatures on incoming confirmations verified with signaturecards for: Authenticity? Compliance with advised signatory authorizations of the

counterparty?

Are all data on each incoming confirmation verified with filecopies of contracts to include: Name?

Currency denomination and amount?

Rate? Transaction date? Preparation date, if different from transaction date? Maturity date? Delivery instructions, if applicable?

Are discrepancies directed to an officer apart from the tradingfunction for resolution?

Is a confirmation discrepancy log or other record maintained toreflect the identity and disposition of each discrepancy?

Are telex tapes retained for at least 90 days as ready reference torates and delivery instructions?

b. Outgoing Confirmations:*

Are outgoing confirmations mailed/telexed on the day duringwhich each trade is effected?

Are outgoing confirmations addressed to the attention of personsother than trading personnel at counterparty locations?

Does the accounting and/or filing system adequately segregate

and/or identify booked contracts for which no incomingconfirmations have been received?

Are follow-up confirmations sent by the confirmation clerk if nocorresponding, incoming confirmation is received within a limited


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27. Is the banks system capable of adequately disclosing sudden increases intrading volume by any one trader?*

28. Do such increases require officer review to insure that the trader is notdoubling volume in an attempt to regain losses in his or her positions?

29. Does the bank retain information on, and authorizations for, all overdraftcharges and brokerage bills within the last 12 months?

30. Does an appropriate officer review a comparison of brokerage charges,monthly, to determine if an inordinate share of the banks business isdirected to or handled by one broker?

Conclusion

31. Is the foregoing information an adequate basis for evaluating internalcontrol in that there are no significant additional internal auditingprocedures, accounting controls, administrative controls, or othercircumstances that impair any controls or mitigate any weaknessesindicated above (explain negative answers briefly, and indicateconclusions as to their effect on specific examination or verificationprocedures)?

32. Based on a composite evaluation, as evidenced by answers to theforegoing questions, internal control is considered ____________ (good,

medium, or bad).


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Foreign Exchange

(Section 813) Verification Procedures

1. Obtain control of all outstanding contracts and number themsequentially so that they may be returned to the bank in the order inwhich they were received, and:

a. Arrange them by currency for preparation of position worksheets forproof to or comparison with:

Foreign currency subsidiary ledgers.

The general ledger.

The banks position report as of the same date.

Net position l imits. Aggregate trading limits.

b. Arrange them by currency and by maturity for preparation of maturityworksheets and for comparison with the banks maturity gap reports,if available, as of the same date, and check for compliance with gaplimits.

c. Arrange them by customer and by maturity, and:

Provide to customer liability ledgers. Check for compliance with customer trading limits.

Check for compliance with customer settlement limits.

d. Test for compliance with other limits, as appropriate.

2. Identify those contracts for which incoming confirmations have not yetbeen received as well as those for which incoming confirmations bearunresolved discrepancies.

a. Unless bank personnel have taken follow-up action too recently toexpect response, prepare and mail confirmation forms to include:

Counterparty name.


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33

Currency denominations and amounts.

Rate.

Transaction date.

Maturity date.

Settlement instructions, if applicable.

3. Using appropriate sampling techniques, select accounts from the trialbalance, and perform the following:

a. Prepare and mail confirmation forms to include the same informationcited in 2a.

b. After a reasonable time, mail second requests.

c. Follow-up on any no-replies or exceptions, and resolve differences.

Confirmation forms and return envelopes should be prepared:

By bank staff under examiner supervision.

On bank letterhead and signed by the auditor.

Using the banks return address with conspicuous markings toinsure their direct routing to the responsible examiner.

4. In conjunction with the audit staff, intercept at the banks mail room allincoming confirmations for a period of several days to determine:

a. If any contracts have been made but not booked.

b. Extent to which the confirmation clerk, or other personnel, reliesupon traders to resolve discrepancies.

foreignex comptroller handbook

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